Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Above Wealth Management LLP (the “Firm”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code”) or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance.

The seven principles of the Code are that institutional investors should:

  • Publicly disclose their policy on how they will discharge their stewardship responsibilities;
  • Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
  • Monitor their investee companies;
  • Establish clear guidelines on when and how they will escalate their activities;
  • Be willing to act collectively with other investors where appropriate;
  • Have a clear policy on voting and disclosure of voting activity; and
  • Report periodically on their stewardship and voting activities.

Above Wealth Management LLP has decided that, whilst it supports the aims of the Stewardship code, it currently has no discretionary mandates and is not, at the present time, offering portfolio management services to investors, the requirements are not presently applicable to the Firm.  Further, the Firm rarely advises clients on individual stock selection and, where it does, positions would be so small as to be immaterial to any issuer.

For further information on the Firm’s approach contact: Anthony Rowland [email protected]